Multistate Tax alert archive | Deloitte US | Multistate Tax Services | Tax


Multistate Tax alert archive

State tax legislative, judicial, and administrative developments

​The Multistate Tax alert archive includes external tax alerts issued by Deloitte Tax LLP's Multistate Tax practice during the last three years. These external alerts highlight selected developments involving state tax legislative, judicial, and administrative matters. The alerts provide a brief summary of specific multistate developments relevant to taxpayers, tax professionals, and other interested persons.

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Most recent Multistate tax alert

Texas combined group controlling interest satisfied by common owners

The Texas Comptroller of Public Accounts (Comptroller) recently issued an order (Comptroller’s order) upholding an Administrative Law Judge decision (ALJ decision), which held that the Comptroller Staff (Staff) erred in: (1) rejecting the amended combined Texas franchise tax reports for Company A and Company B (collectively referred to as the taxpayers), and (2) denying the corresponding refund claims.

Company A and Company B originally each filed separate Texas franchise tax reports for the report years at issue. Subsequently, Company A and Company B filed amended Texas franchise tax reports, as members of the same affiliated group engaged in a unitary business, on a single combined group basis and claimed a refund on their combined Texas franchise tax report. Staff then denied the refund claim arguing that Company A and Company B were not members of the same affiliated group and, thus, were ineligible to file as members of the same combined group because no single shareholder held a controlling interest for both entities. Ultimately, the ALJ decision and the Comptroller’s order sided with the taxpayers and concluded that the requisite controlling interest may be held by the same set of common owners. This tax alert summarizes this “controlling interest” issue and the related analysis in the administrative law judge decision, as well as offers some taxpayer considerations.


2014 Multistate Tax alerts

Find out what you missed in 2014. Explore our archive.

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2013 Multistate Tax alerts

Key updates in 2013. Explore our archive.

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Partner | Deloitte & Touche LLP


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